Mid-Year Review of OSHA’s Site-Specific Targeting Program.


Mid-year review of OSHA’s Site-Specific Targeting Program.

Under the Site-Specific Targeting 2014 Program (SST-14), OSHA has issued its annual inspection plan. After analyzing data collected from a survey of 80,000 establishments, the plan is directing enforcement resources to workplaces focusing on reducing injuries and illnesses.

OSHA’s Site-Specific Targeting program is one of their main programmed inspection plans for non-construction workplaces with 20 or more workers. Also implemented by OSHA are 13 National Emphasis Programs (NEP) and approximately 140 Regional and Local Emphasis Programs that intensify inspections of industries or hazards.

OSHA’s SST-14 Program will require area offices to inspect facilities that meet one or more of the following criteria as outlined in their Primary Inspection List:

  • Manufacturing establishments that meet a Days Away, Restricted, or Transferred (DART) rating of 7.0 or above.
  • Manufacturing establishments that meet a Days Away from Work Injury and Illness (DAFWII) case rating of 5.0 or above.
  • Nonmanufacturing establishments that meet a DART rating of 15.0 or above.
  • Nonmanufacturing establishments that meet a DAFWII case rating of 14.0 or above.

Once all of the inspections from the Primary Inspection List have been completed by an area office, it can proceed with inspections of facilities that meet one or more of the following criteria as outlined in the Secondary Inspection List:

  • Manufacturing establishments that meet a DART rating of 5.0 or above.
  • Manufacturing establishments that meet a DAFWII case rating of 4.0 or above.
  • Nonmanufacturing establishments that meet a DART rating of 7.0 or above.
  • Nonmanufacturing establishments that meet a DAFWII case rating of 5.0 or above.

If an area office completes all inspections on the Secondary Inspection List, the area office will move on to the Regional and Local Emphasis Programs for further inspections. The establishments to be inspected will have a DART rating of 3.6 or higher or a DAFWII case rating of 2.2 or higher.

OSHA’s ongoing 13 National Emphasis Programs are:

Combustible Dust (OSHA Instruction CPL 03-00-008)

  • Federal Agencies (OSHA Notice 13-02 (FAP 01)
  • Hazardous Machinery (OSHA Instruction CPL 03-00-003)
  • Hexavalent Chromium (OSHA Instruction CPL 02-02-076)
  • Isocyanates (OSHA Instruction CPL 03-00-017)
  • Lead (OSHA Instruction CPL 03-00-009)
  • Nursing and Residential Care Facilities (OSHA Instruction CPL 03-00-016)
  • Primary Metal industries (OSHA Instruction CPL 03-00-013)
  • Process Safety Management (OSHA Instructions CPL 03-00-014, CPL 03-00-010)
  • Shipbreaking (OSHA Instruction CPL 03-00-012)
  • Silica (OSHA Instruction CPL 03-00-007)
  • Trenching and Excavation (OSHA Instruction CPL 02-00-069)

The plan is based on survey data and is systematically directing enforcement resources to workplaces with the highest rates of injuries and illnesses.

Source: Wise BusinessWare  http://www.wisebusinessware.com



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“The OSHA SDS/GHS Hazcom Compliance Myth”

GHS SheetAfter the passage of the revised Hazcom standard in 2012, there was a great deal of confusion and misinformation generated regarding the revision from the old standard and format to the new one. This was and still is especially true for employers attempting to comply with “Employee Right to Know (Understand)” rules. By now, everybody knows about the new standardized 16 section format, the new pictograms and hazard phrases, etc. It is also commonly known that the deadline for training employees on how to read and interpret the difference between the old and new format was December 1, 2013. But what about all of the existing (m)SDS’s you have already? What do you need to do to comply with the new Hazcom rule regarding updating your collection of (m)SDS’s?

As someone who works for a company that offers (m)SDS management software, I hear over and over from our clients about the urgent need for them to update their (m)SDS binders so that they would be using the most recent “GHS compliant” version. When I asked them why they wanted to do this, every one of them said it was because they wanted to be compliant with the new GHS rule. When I asked them where they found out about the need to update their library, again almost every reply was unanimous……from a salesperson at a company who offers (m)SDS management software. OSHA compliance is serious business, but that means that there is also serious money to be made to help you maintain compliance. But how much of this is hype and what is really required?

The fact is that you must retain the newest versions of the (m)SDS as you receive them from your suppliers. Beyond that, OSHA does not require you to proactively update your existing collection, as long as your employees know and understand the difference between the new and old format. If one of your suppliers re-authors their (m)SDS into the new format, they are required by law to send you the new revision and you are required to replace the old one you already have with the new one that you received. You are not required to search for updates proactivly.

Keeping in mind that I work for a company that offers (m)SDS management software, I realize that any opinion I espouse should be met with appropriate skepticism. Therefore, please refer directly to what OSHA has said. A letter of clarification was issued on June 13, 2014 to address this issue. Here is the relevent text:

“…OSHA would not issue citations for maintenance of MSDSs when SDSs have not been received….employers may, but are not required to, contact manufacturers or distributers of products they have previously ordered to request new SDSs”.

Here is a link to the full text: OSHA letter of clarification:  http://www.m3vsoftware.com/downloads/OSHA-Letter-of-Clarification.pdf

M3V has been providing web based (m)SDS management tools since 2002. For more information about our products and services, please click:
SDS Explorer
Chemical Management Navigator
EH&S Task Manager
Ross Olsby
M3V Data Management
11925 East 65th Street
Indianapolis, IN 46236

Source: M3V Data Management:  http://www.m3vsoftware.com/News.asp

OSHA QuickTakes – January 16, 2013

OSHA QuickTakes

New resources available on protecting hospital workers, enhancing patient safety

OSHA hosts informal public meeting, extends comment period on proposed rule to improve tracking of workplace injuries and illnesses

Stakeholders join OSHA for silica rulemaking Web chat

Listening sessions seek public input on chemical safety

Assistant Secretary Michaels addresses National COSH Conference, celebrates graduating class of bilingual training program

Reliable Castings Corp. of Ohio fined more than $293,000 for multiple violations including struck-by, crushing and amputation hazards

Tyson Foods cited for safety violations after worker’s hand severed by unguarded machine at Kansas facility

Two trucking companies ordered to pay damages for retaliating against drivers

Connecticut Superior Court dismisses lawsuit by trucking company

NACOSH meeting scheduled for February

New study finds increased risk between silica and lung cancer and need for action to protect workers

Recent fatalities serve as reminder to ensure worker safety during demolition

OSHA renews strategic partnership with electrical transmission and distribution contractors, associations to reduce worker injuries, deaths

Alliance with Scaffold and Access Industry Association renewed to protect workers from scaffold hazards

New and updated OSHA resources available

El Paso office teams with temp worker agency, free consultation program for workplace safety outreach

Phoenix unveils fall protection billboards

Columbus office cohosts construction safety day

New on the DOL blog: OSHA celebrates 43rd anniversary

Help OSHA evaluate its heat illness prevention campaign

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